RPM International Inc.
RPM International Inc, and its affiliates, subsidiaries, and
operating companies (the "Company", "us", "we") is committed to
how we Process Personal Data relating to you, including the types
of Personal Data that we collect, the purposes for which we use it,
the types of third parties with whom we share it, and any rights
you may have with respect to such Personal Data. This Policy
applies to the Personal Data you provide us when you access any of
our websites, including www.rpminc.com (collectively,
referred to as "Website"), when you visit any of our business
locations or facilities, or when you otherwise contact or engage
For the purposes of applicable data protection laws and
regulations, the Company is considered the "Data Controller" in
respect of the Personal Data that it collects, uses and manages in
accordance with this Policy. The Company is part of a multinational
group of affiliated companies that has databases in different
countries, some of which are operated by affiliates and some of
which are operated by third parties on behalf of the Company or its
affiliates. Before you provide us with any Personal Data or
browse our Website, you must read through this Policy in full and
make sure that you are comfortable with our privacy practices and
agree to comply with the terms and conditions set forth herein.
Please note that our Website may contain links to other
websites. These third party sites are not subject to this Policy
and we recommend that you review the privacy and security policies
of each website that you visit. We are only responsible for the
privacy and security of the data that we collect and have no
control over the actions of any third parties in relation to your
Personal Data. Please refer to the Glossary below for an
explanation of the defined terms in this Policy.
Whose Personal Data Do We Collect
The Company collects Personal Data from a range of individuals
in the context of its business activities, including the
- Representatives of our suppliers, customers and other business
- Contractors and similar types of workers.
- Individuals that use, or otherwise access, our Website.
- Consumers and customers.
- Individuals who visit our premises or facilities.
- Job applicants.
- Individuals related to, or otherwise affiliated with, our
- Individuals who contact us by any means.
How We Collect Personal Data
We obtain Personal Data which you knowingly and voluntarily
disclose to us, both in an online and offline context. For example,
when individuals undertake the following activities, we generally
collect their Personal Data:
- Use or access our Website and/or complete one of our web forms
(e.g. using our "Ask the Expert" service).
- Contact our customer service centers or request information
from us in any other way.
- Visit our premises.
- Submit an order to, or make a purchase with, the Company.
- Provide us your contact information via business card or
- Complete a survey or otherwise provide us feedback.
- Communicate with us via social networking websites, third party
applications, or similar technologies.
- Visit one of our trade counters at an exhibition.
We may also collect Personal Data from third party sources. For
example, we may collect information from your employer; publicly
available sources; our service providers, vendors, and other
business contacts for the purposes described herein.
The Categories Of Personal Data We Collect
The Company may collect a range of Personal Data from, or about,
you, during our business activities, such as the following:
- Identity data, such as your name, title, company/organization
name, e-mail address, telephone and fax numbers and physical
address (including street, city, state, postal code, and/or
country). If you visit any of our business locations in
person, we may require you to sign in and provide your name, car
registration number, driver's license number, or other
- Business contact data, such as information related to other
employees, owners, directors, officers, or contractors of a
third-party organization (e.g., business, company, partnership,
sole proprietorship, nonprofit, or government agency) with whom we
may conduct, or possibly conduct, business activities.
- Marketing and communications data, including your marketing
preferences and your subscriptions to our publications.
- Transaction data, including inquiries about and orders for
our products and services and details of payments to and from you,
including purchase order history and information needed to
facilitate payment transactions.
- Customer Feedback, and similar comments, surveys, and
recommendation, including feedback about our Website, products,
services, and data Processing practices.
- Usage data, including information about how you use our
Website, the pages you view, the links you click, the materials you
access, the date and time you access the Website, the website from
which you linked to our Website, and other actions taken within the
Website. We may also collect usage data if you access our internet
services at a Company location or facility.
- Technical data, such as your Internet Protocol (IP) address,
your browser type and capabilities and language and your operating
system. For information about the cookies we use on our Website,
please see below. We may also collect technical data if you access
our internet services at a Company location or facility.
- Biometric data, as further detailed in the section on Biometric
When you do not provide Personal Data that the Company requests,
we may not be able to provide you the requested service or complete
a transaction, and you agree that the Company will not be liable or
otherwise responsible for any actions resulting therefrom.
Data Processing Purposes
Generally, the Company Processes Personal Data for a broad range
of purposes, including the following:
- To provide you with information about, and to fulfil your
requests for, products and services.
- To answer your questions or respond to your feedback or
- To conduct research and advertising.
- To contact you about improved products or product uses.
- To provide you with e-newsletters; email, or other
- To allow you to participate in online support or "Ask the
- To notify you of any changes to your services and to provide
you with information in relation to similar goods and services that
may be of interest.
- To administer and manage warranties
- To communicate with you and third party contacts.
- To enable your participation in promotions, sweepstakes or
- To administer our Website and help improve our products and
- To allow you to report problems with our Website.
- To carry out analytics in relation to the use of our
- To comply with applicable laws, regulations, or other legal or
- To better ensure the security of the Company's property,
locations, and premises.
- To defend our legal, regulatory, and business interests.
- To protect the health and safety of Company's employees,
temporary workers, contractors, agents visitors or any other
individual who may visit our business locations or facilities, for
instance during a pandemic or other health emergencies.
- For other business-related purposes, including negotiating,
concluding and performing contracts, managing accounts and records,
customizing licensed content (as set forth in the Website's Terms
of Use), supporting corporate social responsibility activities,
legal, regulatory and internal investigations, general business
purposes and debt administration.
Please note that you cannot communicate with us through the
"Contact" or support links on the Website or via e-mail without
providing some Personal Data. If you contact us or our
service providers, a record of that session or correspondence will
be maintained in accordance with applicable policy and/or law.
Talent Management And Recruitment
When you apply for employment via our Website or otherwise, we
will collect additional Personal Data about you that is specific to
that employment position, such as your qualifications, career
history, third party references and interview notes. We may also
ask you for other information, for example your interests and the
types of jobs you are interested in. Any Personal Data you provide
to us in relation to an employment application will be processed in
accordance with this Policy and any other privacy statement that
may be included with the job announcement to which you apply.
Legal Basis For Processing
In order to comply with certain applicable data privacy laws,
the Company is required to set forth the legal basis for the
Processing of your Personal Data. In accordance with the purposes
for which we collect and use your Personal Data, as set out above,
the legal basis for the Company's Processing of your Personal Data
will typically be one of the following, which are not mutually
- For the performance of a contract that we have in place with
you or other individuals, or to take steps at your request prior to
entering into a contract.
- To support the Company or our third parties' legitimate
business interests (for example, in maintaining and promoting our
business by providing customers with feedback opportunities).
- To comply with our legal obligations.
- With your consent.
The Company has its corporate headquarters in the United States
and is part of a multinational group of affiliated companies that
has databases in different countries, some of which are operated by
affiliates and some of which are operated by third parties on
behalf of the Company or one of our affiliates. We may
transfer your Personal Data to one or more such databases outside
your country of domicile, potentially including countries which may
not require an adequate level of protection for your Personal Data
compared with that provided in your country, and in which case,
Personal Data may be available to government authorities under
lawful orders and laws applicable in such foreign jurisdictions.
The Company and its affiliates have established reasonable
and appropriate controls as required by applicable law to
safeguard the possession of, and transfer of, Personal Data. If you
are located in the EEA or the UK, you can request a copy of the
safeguards which we have put in place to protect your Personal Data
and privacy rights in these circumstances, using the email address
provided below. By providing the Company any Personal Data, you
hereby consent to its transfer across international borders in
accordance with this Policy.
Sharing And Disclosure Of Personal Data
The Company may share or otherwise disclose your Personal Data
within the Company, to affiliates and subsidiaries, and selected
third parties in accordance with applicable law. The following are
examples of how your Personal Data may be shared and the reasons
and purposes for undertaking such activities:
The Company may share your Personal Data with employees and
other officials and representatives within our parent company,
subsidiaries and affiliates who have a "need to know" that data for
business or legal reasons, for example, in order to carry out an
administrative function such as processing an invoice, or to direct
a query that you have submitted to the relevant department or
We may disclose your Personal Data to third parties, including
the following: law enforcement and regulatory authorities; the
Company's advisors and consultants; IT service providers; third
parties engaged by the Company for the purpose of providing
services requested by you; to protect any intellectual property
rights in any materials displayed on or otherwise available from
the Company's Website; for the purposes of seeking legal or other
professional advice; to respond to a legal request or comply with a
legal obligation; or to enforce the Company's policies or Website
Terms and Conditions of Use.
We may disclose your Personal Data to third parties in the event
that we sell, buy or merge any business or assets, including to the
prospective seller or buyer of such business or assets.
With your consent, we may disclose your Personal Data to third
parties who offer products that may be of interest to you.
These companies may then contact you directly with product or
sample offers, personalized offers and information or to ask for
your feedback on products and programs that may be of interest to
Our employees may use personal devices to access our systems
containing your Personal Data, thus your Personal Data may be
transferred through or to service providers who contract with our
employees for cellular data everywhere in the world.
We may be required to share your Personal Data in order to
comply with a court order, law, or legal process, including to
respond to government or regulatory requests. We may disclose
Personal Data if we have reason to believe that disclosure is
necessary to identify, contact or bring legal action to enforce any
of the Company's rights, including against you or a third party,
for non-payment, violation of any agreement with us, or to
otherwise support our business interests. We may share your
Personal Data to protect the safety of the Company, our customers
or others; or to prevent injury to or interference with, our rights
or property, or the rights or property of other data processors or
anyone else that could be harmed by such activities.
To the extent you engage with the Company for us to provide you,
or a third party, with any of the services or deliverables
described herein, you hereby consent to the disclosure of your
Personal Data to any third party the Company reasonable
determines to be applicable to the provision of the services or
deliverables, provided the third party does not also sell the
Personal Data, unless that disclosure would be consistent with
applicable data protection laws.
We Do Not Sell Personal Data
Without prior consent, the Company does not sell, rent, release,
disclose, disseminate, make available, transfer, or otherwise
communicate orally, in writing, or by electronic or other means,
Personal Data to another business or a third party for monetary or
other valuable consideration.
The Company takes reasonable technical and organizational
security measures to protect Personal Data from accidental or
unlawful destruction or loss and unauthorized access, destruction,
misuse, modification or disclosure. However, no information system
can be fully secure, so we cannot guarantee the absolute security
of your Personal Data. Moreover, we are not responsible for the
security of Personal Data you transmit to us over third-party
operated systems or networks, including the Internet and wireless
networks. You provide the Company with any and all information,
including Personal Data, at your own risk and you hereby agree
that, to the extent permitted by law, the Company shall not be
liable or otherwise responsible for any data incidents that may
compromise the confidentiality, integrity, or security of your
We will keep your Personal Data for as long as we need it for
the purposes set out above, and so this period will vary depending
on your interactions with us and the country in which the Personal
Data is processed. For example, where you have made a purchase with
us, we will keep a record of your purchase for the period necessary
for invoicing, tax and warranty, and liability purposes. We may
also keep a record of correspondence with you (e.g., if you have
made a complaint about a product) for as long as is necessary to
protect us from a legal claim. Please note that where you
unsubscribe from our marketing communications, we will keep a
record of your email address to ensure we do not send you marketing
emails in future.
Your Rights And Responsibilities
You are permitted, and hereby agree, to only disclose or
otherwise provide Personal Data to the Company if such Personal
Data is accurate, reliable, and relevant to our relationship, and
only to the extent such disclosure or provision will not violate
any applicable data protection law, statute, or regulation, or
infringe upon any person's data privacy rights or privileges. Some
data protection laws, such as the General Data Protection
Regulation (EEA),and the California Consumer Privacy Act (United
States), provide individuals with the rights described below. If
you are in the EEA, a California resident, or otherwise afforded
such rights and would like to exercise them in the context of any
of your Personal Data the Company (or a service provider or
processor acting on our behalf) has in our possession, custody, or
control, please contact us, or have your authorized agent contact
us, in accordance with the instructions listed below. In the event
you submit, or your authorized agent submits on your behalf, a data
request, you (and your authorized agent) hereby acknowledge and
agree, under penalty of perjury, that you are (or the authorized
agent of) the consumer whose Personal Data is the subject of the
request. We will respond to any data requests within the timeframes
required by law, and we may charge a fee to facilitate your
request, where permitted by law. If you make, or an authorized
agent on your behalf makes, any request related to your Personal
Data, we will ascertain your identity, or the identify of your
authorized agent, to the degree of certainty required under the law
before addressing your request. For example, the Company may be
required you to match at least two or three pieces of Personal Data
we have previously collected from you before granting you access
to, or erasing, specific pieces, or categories of, Personal Data,
or otherwise responding to your request. We may also request that
the authorized agent provides written documentation that
demonstrates his/her authorization to act on your behalf. The data
privacy rights afforded under data protection laws are not
absolute, and the Company may be permitted to refrain from
undertaking any action or changing its data processing activities,
in response to a data request you submit to us.
Marketing and Unsubscribe. In accordance with applicable law, we
may process your Personal Data for marketing purposes. If, at any
time, you decide that you no longer want to receive commercial
communications from us, whether by email, telephone or post, you
can "opt-out" from receiving such communications by clicking on the
"unsubscribe" link provided at the bottom of each commercial email
and updating your preferences, or by contacting us at firstname.lastname@example.org.
Some jurisdictions provide individuals with the right to request
certain information regarding our disclosure of Personal Data to
third parties for their direct marketing purposes. To the best of
the Company's knowledge, we do not share Personal Data with third
parties with whom we have reason to believe use such information
for their own direct marketing purposes.
Correcting your Information. Keeping your Personal Data
accurate and up-to-date is very important. Inaccurate or
incomplete information could impact our ability to delivery
relevant services to you. Please let us know about any
changes that may be required to your Personal Data via
Accessing and Transferring Personal Data. Some data protection
laws provide individuals with the right to know about, and access,
the Personal Data we have collected about them, including the
categories and specific pieces of Personal Data we have collected;
the categories of sources from which the Personal Data is
collected; the business or commercial purpose for collecting the
Personal Data; the categories of third parties with whom we have
shared, disclosed, or sold Personal Data and the purpose for doing
so. In addition, some jurisdiction provide individuals with the
right to request the Company transfer, to the extent feasible,
Personal Data in certain forms and formats.
Erasing and Deleting Personal Data. Some data
protection laws provide individuals with the right to request that
we (and any applicable service provider or processor acting on our
behalf) delete/erase your Personal Data in our possession, custody,
Object to Processing. Some data protection laws provide
individuals with the right to object to the manner in which the
Company undertakes certain types of Processing involving your
Personal Data, including where we are relying on a legitimate
business interest for such Processing or engaging in direct
Restriction of Processing. You may be entitled to request
that we restrict our Processing of your Personal Data, for example,
in circumstances in which the accuracy of the Personal Data is
Do Not Track Signals. Some web browsers may transmit
"do-not-track" signals to websites with which the user
communicates. Because of differences in how web browsers
incorporate and activate this feature, it is not always clear
whether users intend for these signals to be transmitted, or
whether they even are aware of them. We currently do not take
action in response to these signals.
Anti-Discrimination. Some data protection laws provide the
organizations are prohibited from discriminating against
individuals for exercising their data privacy rights. The
Company does not, under any circumstances, intend or otherwise seek
to discriminate against individuals for any reason, including for
exercising a data privacy right.
Persons with Disabilities. The Company strives to ensure that
every person has access to information related to our products and
services, including this Policy. Please contact us if you would
like this Policy provided in an alternative format and we will take
commercially reasonable measures to meet your needs.
Complaints. Some data protection laws afford individuals
the right to lodge a complaint about an organization's Processing
with government or regulatory authorities. For example,
individuals in the EEA have the right to lodge a complaint with the
competent Data Protection Authority, a list of which can be
accessed at: https://edpb.europa.eu/about-edpb/board/members_en.
Children's Personal Data
The Website and services are not intended for "children," which
may be defined differently within applicable data protection laws.
We do not knowingly Process information of children under the age
of sixteen (16) without the consent of their parents or legal
guardians and you are hereby prohibited from providing the Company
with any such information. In an instance where such
information was collected, it would be purely accidental and
unintentional. By using our Website or otherwise providing us with
Personal Data, you hereby represent that you are over the age of
sixteen (16) and the Personal Data does not relate to any person
under the age of sixteen (16).
Where permitted by law and in certain limited circumstances, the
Company may collect biometric data and other biometric identifiers
related to our customers, suppliers, service providers, employees,
temporary workers, contractors, or agents, for instance, during a
pandemic or other health related emergencies. The Company may use
cameras, kiosks, and similar devices to collect, retain, and use
information derived from the scanning of a person's facial geometry
(i.e., biometric identifiers) in order to facilitate temperature
screening as part of the Company's health and safety screening
programs, and for other security-related purposes. In other
circumstances, the Company may collect the same type of data from
individuals that are accessing sensitive areas of the Company's
facilities or for other administrative (e.g., timekeeping) or
security functions and purposes. The Company will retain such
biometric identifiers for no longer than as is permitted by law,
but in no event longer than one (1) year after the applicable
individual's last interaction with the Company. The Company will
implement and maintain protocols for the security and permanent
destruction, or disposal of, biometric identifiers in a manner that
complies with applicable data protection law and renders such data
and identifiers unreadable so as to remove any potential for its
reuse or re-identification. Barring any applicable law to the
contrary, the Company may disclose and disseminate biometric
identifiers to third parties in the same manner as it may disclose
and disseminate Personal Data to third parties in accordance with
may include to third party service providers and law enforcement or
regulatory agencies, where permitted by law.
Non-Personal Data Information & Cookies
Non-Personal Data is information that does not identify you as
an individual, either directly or indirectly. The Company, either
directly or through third parties, may automatically collect
certain types of Non-Personal Data from you when you are using
the Company's Website. We may also collect Non-Personal Data that
you voluntarily provide, such as information included in response
to a questionnaire or survey.
We may share Non-Personal Data with other third parties that are
not described above. When we do so we may aggregate or de-identify
the information so that a third party would not be likely to link
data to you, your household, your computer, or your device.
Aggregation means that we combine the Non-Personal Data of numerous
people together so that the data does not relate to any one person.
De-identify means that we attempt to remove or change certain
pieces of information that might be used to link data to a
Except for any Personal Data the Company may collect from you as
described in this Policy, any material, information or other
communication you transmit, upload or post to the Website or email
to the Company ("Communications") will be considered
non-confidential and non-proprietary. The Company will have no
obligation to preserve the confidentiality or refrain from
disclosing Communications. The Company will have no liability
for and will be free to copy, disclose, distribute, incorporate and
otherwise use the Communications and all data, images, sounds,
tests, product ideas, suggestions or enhancements, as well as
anything embedded therein for any and all commercial or
In general, you may visit the Website without telling the
Company who you are or revealing Personal Data about
yourself. However, the Company and companies providing
services to or on behalf of the Company may use various
technologies, such as cookies and web beacons (1x1 pixels), to
collect non-Personal Data discernible as a result of your visit. We
Website. Cookies are used to collect general usage and volume
browser (visit www.aboutcookies.org for
more information); however, if you reject cookies some or all of
your ability to use our Website may be limited. In addition
to using cookies, we use Google Analytics to analyze trends,
administer the Website, track movements around the Website and
gather demographic information about our user base as a
whole. To opt of out being tracked by Google Analytics across
all Websites visit http://tools.google.com/dlpage/gaoptout.
We also use tools provided by Addthis.com, and you can receive more
They may also use and disclose non-Personal Data derived from our
advertising campaigns for reporting purposes, for scheduling and
optimization of content delivery and, of course, they may do so if
they are required to do so by law. The Company may use any
information gained through its Website for any legal purpose,
including without limitation, for purposes of developing, using and
making available to third parties (at no charge or for a fee)
aggregated information regarding trends, products, security/privacy
patterns and research, internal record keeping and reporting,
measuring and reporting learning, performance and other statistical
information concerning any aspect of the Website except that the
Company will not report aggregated data in a manner that reasonably
permits such information to be identified with any user.
Social Media Features
Our Website may also include social media or lead generation
features, such as Facebook or Twitter buttons and widgets, such as
the "share this" button. These features may collect your IP
address, which page you are visiting on our Website and may set a
cookie to enable the feature to function properly. Social
media and lead generation features and widgets may be hosted by a
third party. Your interactions with these features and
it. For more information, please visit any of the following http://www.aboutads.info/choices/, http://optout.networkadvertising.org,
Questions and complaints
If you have a concern or complaint about how the Company has
used your Personal Data, or to exercise any data protection
rights afforded to you under the law, please contact us at any of
the following: email@example.com, https://rpminc.com/contact/,
or at 1 (800) 776-4488.
Changes to this Policy
We reserve the right to modify or amend this Policy at any time
by posting the revised Policy on our Website. It is your
responsibility to review the Policy every time you submit
information to us or place an order.
A party that determines the purposes and means of data
Data Protection Authority
The relevant supervisory authority with responsibility for
privacy or data protection matters in the jurisdiction of the
Company and/or affiliate;
European Economic Area (EEA)
The EEA includes all European Union member states and Iceland,
Liechtenstein and Norway. For purposes of this Policy, the
EEA will include the United Kingdom in the event it leaves the
Information that is subject to an applicable data protection law
which relates to an identified or identifiable individual and
may include names, addresses, email addresses, job
applications, user account information, correspondence, web
browsing information (e.g. data associated with a particular
cookie) and IP addresses, when such information can be linked to an
Doing anything with Personal Data; this includes collecting
it, storing it, accessing it, combining it with other data, sharing
it with a third party, or even deleting it.
Last updated September 8, 2020.